Matter of Singleton v. New York State Off. of Children & Family Servs.
Petitioner Charles Singleton challenged the termination of his employment by the New York State Office of Children and Family Services (OCFS) following the expiration of his workers' compensation leave. He contended that his work-related injury was assault-related, entitling him to a two-year leave rather than the one-year leave OCFS granted for a non-assault injury. After his employment was terminated, Singleton initiated a CPLR article 78 proceeding seeking reinstatement or a post-termination hearing to dispute the injury classification. The Supreme Court dismissed his petition as untimely, ruling that the four-month statute of limitations began when he received OCFS's August 25, 2015 letter classifying his injury. The Appellate Division affirmed this decision, finding that the classification became final and binding upon receipt of the letter, as no administrative procedure existed for challenging such a determination.